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Privacy Policy

OnPoint Media Corp. ("we," "us," or "our") operates the website https://ratebyfresh.com and the Rate by Fresh mobile application (the "App"). This Privacy Policy explains how we collect, use, and share information about you when you visit our website or use our App.

1. Information We Collect

We may collect the following types of information:

  • Personal details (name, email, photos)
  • Usage analytics (IP address, device/browser type)
  • Cookies and tracking technologies

Cookies and similar technologies may be used on the website. The iOS App does not use IDFA, advertising identifiers, or App Tracking Transparency tracking, and we do not link iOS App data with third-party data for advertising or share iOS App data with data brokers.

2. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal information under the following legal bases: consent, contractual necessity, legal obligation, or legitimate interests.

3. How We Use Your Information

We use the information we collect to:

  • Provide and maintain our services
  • Personalize and improve your experience
  • Communicate with you about updates and offers
  • Analyze usage patterns and improve our App

4. Sharing Your Information

We may share your information with:

  • Service providers who assist in operating our services
  • Legal authorities when required by law
  • Third parties in connection with business transfers or acquisitions

5. International Data Transfers

Your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. We ensure that appropriate safeguards are in place to protect your data when it is transferred internationally.

6. Face Data, Photos, and TrueDepth Data

The App may ask you to capture or select face photos so it can generate appearance analysis, recommendations, hairstyle previews, skin and hair guidance, progress history, and related app features.

  • Face photos and generated analysis may be stored locally on your device so you can view scan history and results.
  • When you choose to run live AI features, relevant photos, image metadata, and analysis context may be sent through our authenticated backend services to service providers that process the request only to provide the requested app functionality.
  • Third-party AI service providers currently include OpenAI, Google Gemini, and Anthropic Claude. Requests are routed through RateByFresh's authenticated Firebase backend; the iOS App does not contain provider API keys.
  • Before the iOS App sends personal data to AI providers, it shows an AI processing permission screen that identifies the data sent and the provider categories. If you do not allow AI processing, the feature is not run.
  • We require service providers to process this information only for the requested app functionality and to protect it under confidentiality and security terms that provide the same or equivalent protection.
  • We do not use face photos, analysis results, or face-related data for advertising, tracking, identity recognition, or biometric identification, and we do not sell face data.
  • On supported devices, the onboarding scanner visualization may use Apple ARKit/TrueDepth face tracking to render a temporary face mesh, point cloud, or camera preview on device.
  • TrueDepth/ARKit face geometry, depth, and related face-tracking data are used only to render that local onboarding visual effect. This TrueDepth data is not uploaded to our servers, not shared with third parties, not stored by us, and is discarded when the AR session ends.
  • You can delete local app data in the Account screen. This clears locally stored scan history, image artifacts, generated results, plans, coach history, onboarding preferences, reminder settings, and scheduled local reminders. This does not cancel or delete App Store subscription records.

7. Your Rights (GDPR and CCPA)

You have the following rights regarding your personal information:

  • Right to access your personal data
  • Right to correction of inaccurate data
  • Right to deletion of your data
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • California residents: Right to opt-out of data sales

To exercise these rights, please contact us at admin@ratebyfresh.com.

8. Data Security

We take reasonable measures to protect your information from unauthorized access, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure.

9. Children's Privacy

Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website and updating the "Effective Date" at the top of this page.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

OnPoint Media Corp.
Email: admin@ratebyfresh.com